On compliance: Four pillars of an effective BSA/AML program

Thoughtful adoption of these will make your Bank Secrecy Act/Anti Money Laundering efforts more effective

by James M. Deitch and Anthony Nguyen, CPA, CU Management

Managing Bank Secrecy Act/Anti-Money Laundering risk requires careful and extensive planning and governance. A credit union should establish a sound BSA/AML program to properly identify, measure, monitor, and control its risks. BSA/AML regulatory enforcement actions can greatly impair a credit union’s image and reputation.

There are four pillars to an effective BSA/AML program: 1) development of internal policies, procedures, and related controls, 2) designation of a compliance officer, 3) a thorough and ongoing training program, and 4) independent review for compliance.

National Credit Union Administration guidelines require that credit unions periodically perform a comprehensive risk assessment of their BSA/AML programs.

The Federal Financial Institutions Examination Council’s BSA/AML Risk Assessment also is an important tool for quantitatively and qualitatively documenting your program’s effectiveness.

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